After much scrutiny including at least one ongoing class-action lawsuit, I noticed yesterday, your company issued a much-publicized report sharing its new anti-discrimination policy.

The report does a tremendous job of demonstrating Airbnb has put a lot of internal energy, resources and thought into this effort, including bringing on former US Attorney General Eric Holder as an adviser.

However, in my opinion, the 32-page report falls several steps short of actually addressing ongoing discrimination on the platform.

Before I qualify why I’ve come to this conclusion, despite the obvious positive and public steps Airbnb is taking, I want to explain why this is important to me.

I am an avid student of the online travel industry.

I can clearly detail the strengths and weaknesses of travel-centric companies like Priceline and TripAdvisor or spend hours discussing Google’s and Facebook’s growing influence on the sector, but one particular travel company, your company, Airbnb, has been of keen interest over the years.

This is largely because my job as the founder and CEO of Localeur, a travel startup focused on helping Millennial travelers discover the best local places to eat, drink and play.

I’ve long believed that Airbnb could one day be a tremendous partner for us, and perhaps that can still occur if this feedback is welcomed, as is my genuine hope.

But I’ve also been enamored with Airbnb over the years because I’m a very frequent traveler.

I’ve traveled over 100 days a year for seven straight years, and although I prefer boutique hotels like the Standard Hotel in Miami, I’ve stayed in Airbnb accommodations on 45 separate occasions since Localeur’s launch at SXSW 2013.

As a startup founder working on wages nearly one-fifth of what I made in my last job, I often choose to book with Airbnb for its affordability and being able to pick the specific neighborhood I need to be in for meetings with our Localeurs and business partners.

In Airbnb, I’ve been inspired by a startup actually founded by Millennials and catering to us Millennials.

In Airbnb, I’ve also been inspired by an online travel startup which has truly re-written the book on innovation in the oft-latent $1.3 trillion travel industry, becoming a $30 billion company (and raising $3.4 billion) in the process. I used HotelTonight a ton, too, but what Airbnb has done is at another level entirely. It’s impressive.

That’s why this discrimination issue has such massive implications: Airbnb could very well be putting down a moat around how Millennials travel for years to come, a generation estimated to carry a lifetime value of around $10 trillion as travelers.

After reading your anti-discrimination policy, I thought to myself that while the travel startup founder in me is deeply inspired by what you, Joe Gebbia, Nate Blecharczyk and team have built with Airbnb, I am profoundly disappointed in both the company’s latency in addressing discrimination, and, now, I’m disappointed by the anti-discrimination policy set forth in your report, which falls short on impact.

I earlier mentioned I’ve used Airbnb successfully some 45 times, which may lead someone to believe discrimination hasn’t been an issue for me at all.

What I didn’t mention is that I’ve personally experienced discrimination on Airbnb on a number of occasions, including cancelled bookings seemingly for no reason at all, including at least one that took place through Instant Booking, the very product initiative Airbnb touts as a potential anti-discrimination tool.

With an African-sounding name like Joah, that is routinely mispronounced for Josh or Joel or, the more common, Jonah, and a profile picture clearly showing my afro hair style and dark brown skin, I didn’t even wonder why discrimination occurred.

Like Blacks have done for decades interacting with the often white male-dominated business world, I simply had to keep my head down, take the slight in stride and continue on.

Of course, today, I can opt toward a more diversity-friendly platform like Noirbnb, but with two million homes on Airbnb makes your inventory nearly impossible to match.

An outside consultant, former ACLU director, Laura Murphy, actually authored the report by the looks of it.

I understand US Presidents and Congress commissioning reports by outside experts to remove the potential for bias and remain objective in delivering policy recommendations, but a private technology company which is in the business of building a product, generating revenue and growing a community doing so on a matter this significant demonstrates to me that Airbnb itself may lack the internal leadership to address this issue for the long-term.

Must you keep consultants on the payroll to ensure discrimination does not continue?

Question is: if Airbnb viewed discrimination as a product, revenue-related or community issue, wouldn’t you have put a product executive, business leader or internal community management leader in charge of the report rather than an outside consultant?

Every mention of the name Brian Chesky and Airbnb is in the third person yet the report itself is on Airbnb brand documents leading me to believe either Airbnb employees had great influence on the final report, reducing its objectivity, while also keeping itself slightly removed from the policy recommendations publicly or it was done this way to diminish the company’s, its executives’ and the Airbnb product’s own role in creating and/or ignoring this issue before it became a newsworthy event.

Despite you routinely saying this is an important, executive-level issue for the company and despite the company’s attempts through social media to give a unified front look of openness – including having employees pose with posters that read #blacklivesmatter and getting prominent Black travelers to speak at your upcoming Open conference – the report leaves me with the feeling that Airbnb wants this issue to go away through policy so your team can get back to the real focus areas of the business like marching toward a multi-billion dollar IPO or launching new product initiatives for Millennials.

2. Airbnb hopes to limit bias, but is not willing to take steps to eliminate it

Airbnb may lose some Black travelers as a result of discrimination, but the bigger area of focus for the company is its hosts base, which is more likely to be white than Black or any other ethnicity.

The report pretty much makes that clear to me. The Open Door policy doesn’t truly punish the potentially discriminating hosts, but instead forces the guests to wave a white flag and get Airbnb’s help to secure alternative lodging.

To me, this is a case of leveraging the perception of equality when the true problem is one of equity.

What this means is, from a bottom line perspective, Airbnb may view itself as having more to lose than gain by taking all necessary steps to eliminate racism.

Case in point, the report points to Instant Book as a product-driven measure that could have positive impacts on limited discrimination.

In the report’s opening, Laura Murphy writes:

“Airbnb is engaging in frank and sustained conversations about bias on its platform. More noteworthy, however, Airbnb is putting in place powerful systemic changes to greatly reduce the opportunity for hosts and guests to engage in conscious or unconscious discriminatory conduct.”

But, truthfully, is it accurate to call a push toward more Instant Book listings one tied to Airbnb’s effort to limit discrimination?

When Instant Book was introduced then scaled out nearly three years ago, there was no statement about doing so to eliminate discrimination or prevent bias, but instead to “make life easier” for hosts (read: make it easier for them to make money).

So to tout Instant Book as a real change in policy to prevent discrimination is a bit of slight of hand intended to mask the pursuit of equality (every user unlocking Instant Book) while ignoring equity (Airbnb’s mostly white U.S. host base).

“Airbnb has chosen not to make the changes that would lead to the largest reduction in the extent of discrimination,” says Michael Luca, a co-author in the ongoing study through Harvard Business School that found hosts were more likely to discriminate against guests with names that sounded African-American, in an interview with the Christian Science Monitor.

“Instead, they’ve proposed a series of smaller changes in the hope that that would also have a nontrivial effect on discrimination.”

“For instance, if customers are able to instantly book a place without the need for host approval, what happens to that customer if they arrive on someone’s doorstep who refuses to let them in or worse?”

3. Airbnb’s definition of trust is simply not good enough for this important occasion in the company’s stage. Airbnb should lead

From Murphy’s report:

“Airbnb believes profile photos are an important feature that help build relationships and allow host and guests to get to know one another before a booking begins.”

“The company’s decision to keep mandatory profile pictures and support that decision by a study that didn’t factor in race overlooks the damaging stereotypes attributed to people of color — that they aren’t trustworthy.”

Simply put, it’s very easy for a mostly-white company with white, male founders to subscribe to the belief that “while important, photos capture only one dimension of a person’s identity”, as the report touts, because you’re less likely to have experienced the kind of subtle racism and discrimination that happens on platforms that require profile photos.

It’d be like trying to tell a Black woman that her experience on Tinder is the same as that of a white woman, when we know enough about the world and biases to know this to be untrue.

In short, like too many Americans who continue to believe Donald Trump is not actually racist, Airbnb has opted to lend its trust to the majority of its users – non-Blacks – rather than the minority most likely to be discriminated against.

The benefit of the doubt has fallen not on guests denied, but hosts being paid.

My hope

In summary, as someone likely on the high end of Airbnb usage and an avid follower of the online travel industry, I am disappointed by your company’s anti-discrimination policy.

The policies are heavy on good intentions, powerful statements and the spirit of openness, all things I applaud you for, but the report is far too light on truly systematic product recommendations.

Considering so much of Airbnb’s success story, your personal success story as a founder and technology leader, is rooted in product design and branding, it’s a sobering thought to think that a company I personally have been quite passionate about for many years may lose me as a customer, negatively impacting my own future travel and my hope of one day partnering with Airbnb, if you continue on this path.

This path is one that, in my opinion, seeks not to truly eliminate discrimination but instead to subtly put forth policies that are largely championed by outside consultants who have little interaction with the day-to-day workings of Airbnb or its product, and a path that does more to attack the publicity issue this discrimination has attracted more than actually tackle the well-publicized issues that may require you to sacrifice short term revenue but would truly reflect Airbnb’s message of openness and trust in the long-term, leading to greater sustainability, equality and equity in travel.

My hope is that you and your executive team, not just the paid consultants, but also the people in charge of your product, are able to continue this evaluation process not with the sense of urgency of a publicity crisis but with the conviction and passion of a product innovation.

This passion is how Airbnb got where it is today, and I know it will continue to serve you well as you transition, eventually, into a publicly-traded company with massive global and local implications on housing, travel and consumer behavior.

Respectfully,

Joah Spearman

PS – Your company, like other online travel giants, could one day seek to partner with or acquire Localeur.

This is something I had to consider before publishing this, but how can I expect you and your team to address discrimination in travel – particularly for Millennials who want to “live like a local” – if I, myself a Black founder helping travelers experience local, am unwilling to speak on a major issue I’ve personally experienced?

I would be a hypocrite and, worse, be giving you a pass on an extremely important issue both for your company and for the very travelers I intend to serve.